Revision 2 to Transnuclear, Inc. Application for Revision ...

[Pages:30]AI

TRANSNUCLEAR

AN AREVA COMPANY

April 20, 2010 E-29128

U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852

Subject:

Revision 2 to Transnuclear, Inc. (TN) Application for Revision 3 to Certificate of Compliance No. 9302 for the Model No. NUHOMS?-MP197 Packaging Response to Request for Additional Information (Docket No. 71-9302, TAC No. L24336)

Reference:

Letter from Eric Benner (NRC) to Donald Shaw (TN), "Request for Additional Information for Review of the Model No. NUHOMS?-MP197 Packaging, Docket No. 71-9302," December 2, 2009

This submittal provides responses to the request for additional information (RAI) forwarded by the referenced letter. Enclosures 2 and 3 herein provide each of the NRC staff RAI followed by a TN response for non-proprietary items and proprietary items, respectively. Enclosures 5 and 7 provide changed safety analysis report (SAR) pages and drawings, for the proprietary and non-proprietary versions, respectively. In the SAR, changed pages are annotated as Revision 7, with changed areas indicated by italicized text and revision bars. Enclosure 36 provides a list of changed SAR pages and drawings with the reasons for changes indicated. Instructions for SAR page and drawing removal and insertion are provided in Enclosures 4 and 6, for the proprietary and non-proprietary versions, respectively.

In addition to changes related to the RAI, Enclosure 31 describes items which also caused changes to the SAR included in this submittal. Additional enclosures listed are referenced from within RAI responses.

This submittal includes proprietary information which may not be used for any purpose otherthan to support your staff's review of the application. In accordance with 10 CFR 2.390, I am providing an affidavit (Enclosure 1) specifically requesting that you withhold this proprietary information from public disclosure. This submittal also includes security-related information. Accordingly, public versions of TN SAR drawings and pages are provided in Enclosure 7, and public versions of certain TN calculations are provided in Enclosures 30, 37 and 38. Because Enclosure 9 consists of computer files that are entirely proprietary, public versions are not provided. Because Enclosures 10 and 11, 16 through 21, and 24 through 26, consist of entirely-proprietary information not owned by TN, public versions are not provided.

Should the NRC staff require additional information to support review of this application, please

do not hesitate to contact Donis Shaw at 410-910-6878 or me at 410-910-6930.

Sincerely,

Jayant Bondre, PhD Vice President - Engineering

7135 Minstrel Way, Suite 300, 'Columbia, MD 21045 Phone: 410-910-6900 * Fax: 410-910-6902

TN E-29128 April 20, 2010

Page 2 of 3

cc: Christopher Staab (NRC SFST), as follows:

* Six copies of this cover letter and Enclosures 1 through 5, 31 and 36 * One copy of Enclosures 8 through 29, and Enclosures 32 through 35

Enclosures:

1. Affidavit Pursuant to 10 CFR 2.390 2. RAIs and Responses (non-proprietary information) 3. RAIs and Responses (proprietary information) 4. Page and Drawing Change Instructions for the NUHOMS?-MP1 97 Safety Analysis

Report Pages, Revision 7 (Proprietary version) 5. Replacement and New NUHOMS?-MP1 97 Safety Analysis Report Pages, Revision 7

(for the Proprietary version) 6. Page and Drawing Change Instructions for the NUHOMS?-MP197 Safety Analysis

Report Pages, Revision 7 (Non-proprietary version) 7. Replacement and New NUHOMS?-MP1 97 Safety Analysis Report Pages, Revision 7

(for the Non-proprietary version) 8. Listing of Disk Numbering and Contents for Computer Files 9. Computer Files associated with RAI 3-21, 5-11, 5-20, and P6-1 (Proprietary), as follows:

a. Part 1 of 3 - Structural Files on a portable hard drive b. Part 2 of 3 - Thermal Files on a portable hard drive c. Part 3 of 3 - Nuclear Files on DVDs 10. DI/RI-A-5-02, Rev. 1 e (original, in French) associated with RAI 2-12 (Proprietary) 11. DI/RI-A-5-02, Rev. 1 e (unofficial English translation) associated with RAI 2-12 (Proprietary) 12. Tietz, T. E., "Determination of the Mechanical Properties of a High Purity Lead and a 0.058 % Copper-Lead Alloy," WADC Technical Report 57-695, ASTIA Document No. 151165, Stanford Research Institute, Menlo Park, CA, April, 1958, associated with RAIs 2-14 and 2-24 13. Cover Page and Pages 56 and 66 from NUREG/CR-0481, associated with RAI 2-14 14. Cover Page and Page 3-110 from "Handbook of Heat Transfer Fundamentals," Second Edition, Warren M. Rohsenhow, James P. Hartnett, Ejup N. Ganic, McGraw-Hill Book Company, associated with RAI 2-14 15. Blandford, Robert K. and Spencer D. Snow, "Impact Testing of Stainless Steel Material at Cold Temperatures," 2008 ASME Pressure Vessels and Piping Division Conference, Chicago, Illinois (PVP2008-61215), associated with RAI 2-26 16. Pole de Plasturgie de I'Est Test Report, "Tests and Characterization of Aluminum Hydroxide-Based Vinylester Materials", November 1999 (original, in French), associated with RAIs 5-4, 5-5, 5-6, and 8-2 (Proprietary) 17. Pole de Plasturgie de I'Est Test Report, "Tests and Characterization of Aluminum Hydroxide-Based Vinylester Materials", November 1999 (unofficial English translation), associated with RAIs 5-4, 5-5, 5-6, and 8-2 (Proprietary) 18. Pole de Plasturgie de I'Est Test Report, "Characterization of Formulations VYAL A VYAL B - VYMA 2", June 2001 (original, in French), associated with RAIs 5-4, 5-5, 5-6, and 8-2 (Proprietary) 19. Pole de Plasturgie de I'Est Test Report, "Characterization of Formulations VYAL A VYAL B - VYMA 2", June 2001 (unofficial English translation), associated with RAIs 5-4, 5-5, 5-6, and 8-2 (Proprietary)

TN E-29128 April 20, 2010

Page 3 of 3

20. SERAM Test Report, "Ageing study of polymer materials for neutron shielding (VYAL B and VYMA 2)", November 2001 (original, in French), associated with RAIs 5-4, 5-5, 5-6, and 8-2 (Proprietary)

21. SERAM Test Report, "Ageing study of polymer materials for neutron shielding (VYAL B and VYMA 2)", November 2001 (unofficial English translation), associated with RAIs 5-4, 5-5, 5-6, and 8-2 (Proprietary)

22. Transnuclear Calculation MP197HB-0503, Revision 1 associated with RAI 5-20 (Proprietary)

23. Cover page and Pages 4-35, 4-36 and 4-37 from Wood Handbook, "Wood as an Engineering Material," Forest Products Laboratory, General Technical Report, FPLGTR-1 13, United States Department of Agriculture," 1999, associated with RAI 2-29

24. DI-DRI-A-1-7-04, Rev. 00 (original, in French) associated with RAI 2-29 (Proprietary) 25. DI-DRI-A-1-7-04, Rev. 00 (unofficial English translation) associated with RAI 2-29

(Proprietary) 26. Figure 3.2 and 3.3 from BLK 99-074, rev 2, and Pages 45 to 49 from BTF 01-221, rev 0,

associated with RAI 2-16 (Proprietary) 27. B. ROQUE et al., "Experimental Validation of the Code System "DARWIN" for Spent

Fuel Isotopic Predictions in Fuel Cycle Applications," Proceedings of the International Conference on the New Frontiers of Nuclear Technology, PHYSOR 2002, Seoul, Korea, October 2002, associated with RAI P6-7 28. B. ROQUE et al., "The French Post Irradiation Examination Database for the validation of depletion calculation tools," proceedings of the International Conference on Nuclear Criticality Safety, ICNC-2003, Tokai-mura, Japan, October 2003, associated with RAI P6-7 29. NRC Safety Evaluation Report, "Safety Evaluation of Topical Report BAW-10228P, SCIENCE," USNRC, October 26,1999, TAC NO. MA4599, associated with RAI P6-7 30. Public Version of Enclosure 22, Transnuclear Calculation MP1 97HB-0503, Revision 1 31. Additional Items, Not Related to the RAI, Which Caused SAR Changes 32. Transnuclear Calculation MP1 97HB-0401, Revision 2 associated with RAI 3-21 (Proprietary) 33. Transnuclear Calculation MP197HB-0402, Revision 2 associated with RAI 3-21 34. Transnuclear Calculation MP197HB-0410, Revision 0 associated with RAI 3-21 (Proprietary) 35. A Survey of Strain-Rate Effects for Some Common Structural Materials Used in Radioactive Material Packaging and Transportation Systems, BMI-1954, associated with RAI 2-14 36. List of Changed SAR Pages and Drawings, with Indication of the Reasons for Changes 37. Public Version of Enclosure 32, Transnuclear Calculation MP1 97HB-0401, Revision 2 38. Public Version of Enclosure 34, Transnuclear Calculation MP1 97HB-041 0, Revision 0

Enclosure 1 to TN E-29128

AFFIDAVIT PURSUANT TO 10 CFR 2.390

Transnuclear, Inc.

)

State of Maryland

SS.

County of Howard

)

I, Jayant Bondre, depose and say that I am a Vice President of Transnuclear, Inc., duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.390 of the Commission's regulations for withholding this information.

The information for which proprietary treatment is sought is contained in various enclosures,

as listed below:

Enclosure 3: Proprietary RAIs and Responses

Enclosure 5:

1) SAR drawings, as follows: * MP197HB-71-1001 Rev 1 * MP197HB-71-1002 Rev 1 * MP197HB-71-1003 Rev 1 * MP197HB-71-1004 Rev 1 * MP197HB-71-1005 Rev 1 * MP197HB-71-1008 Rev 1 * MP197HB-71-1009 Rev 1 * NUH24PTH-71-1003 Rev 1 * NUH32PTH TYPE 1-71-1001 Rev 1 * NUH32PTH TYPE 1-71-1003 Rev 1 * NUH32PTH TYPE 1-71-1004 Rev 1 * NUH32PTH1-71-1003 Rev 1 * NUH32PTH-71-1001 Rev 1 * NUH32PTH-71-1002 Rev 1 * NUH32PTH-71-1015 Rev 0 * NUH37PTH-71-1001 Rev 1 * NUH37PTH-71-1002 Rev 1 * NUH37PTH-71-1003 Rev 1 * NUH37PTH-71-1004 Rev 1 * NUH37PTH-71-1011 Rev 1 * NUH37PTH-71-1012 Rev 1 * NUH37PTH-71-1015 Rev 0 * NUH61BT-71-1001 Rev 1 * NUH61BTH-71-1100 Rev 1 * NUH61BTH-71-1102 Rev 1 * NUH61BTH-71-1106 Rev 1 * NUH69BTH-71-1001 Rev 1 * NUH69BTH-71-1002 Rev 1 * NUH69BTH-71-1003 Rev 1 * NUH69BTH-71-1004 Rev 1

* NUH69BTH-71-1011 Rev 1 * NUH69BTH-71-1012 Rev 1

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Enclosure 1 to TN E-29128

* NUH69BTH-71-1013 Rev 1 * NUH69BTH-71-1014 Rev 1 * NUH69BTH-71-1015 Rev 1 * NUHRWC-71-1001 Rev 0 * NUHRWC-71-1002 Rev 0 * NUHRWC-71-1003 Rev 0 2) SAR Appendix A.2.13.11 3) Portions of SAR Chapter A.3 4) Portions of SAR Chapter A.5 5) Portions of SAR Chapter A.6 6) Portions of SAR Appendix A.6.5.1 7) Portions of SAR Appendix A.6.5.2 8) Portions of SAR Appendix A.6.5.3 9) Portions of SAR Appendix A.6.5.4 10) Portions of SAR Appendix A.6.5.5 11) Portions of SAR Appendix A.6.5.6 12) Portions of SAR Appendix A.6.5.7 13) Portions of SAR Chapter A.7 14) Portions of SAR Chapter A.8

Enclosure 9 - Computer Files associated with RAI 3-21, 5-11, 5-20, and P6-1

Enclosure 10 - DI/RI-A-5-02, Rev. 1 e (original, in French) associated with RAI 2-12

Enclosure 11 - DI/RI-A-5-02, Rev. 1 e (unofficial English translation) associated with RAI 2-12

Enclosure 16 - Pole de Plasturgie de I'Est Test Report, "Tests and Characterization of Aluminum Hydroxide-Based Vinylester Materials", November 1999 (original, in French), associated with RAIs 5-4, 5-5, 5-6, and 8-2

Enclosure 17 - Pole de Plasturgie de I'Est Test Report, "Tests and Characterization of Aluminum Hydroxide-Based Vinylester Materials", November 1999 (unofficial English translation), associated with RAIs 5-4, 5-5, 5-6, and 8-2

Enclosure 18 - Pole de Plasturgie de I'Est Test Report, "Characterization of Formulations VYAL A - VYAL B - VYMA 2", June 2001 (original, in French), associated with RAIs 54, 5-5, 5-6, and 8-2

Enclosure 19 - Pole de Plasturgie de I'Est Test Report, "Characterization of Formulations VYAL A - VYAL B - VYMA 2", June 2001 (unofficial English translation), associated with RAIs 5-4, 5-5, 5-6, and 8-2

Enclosure 20 - SERAM Test Report, "Ageing study of polymer materials for neutron shielding (VYAL B and VYMA 2)", November 2001 (original, in French), associated with RAIs 5-4, 5-5, 5-6, and 8-2

Enclosure 21 - SERAM Test Report, "Ageing study of polymer materials for neutron shielding (VYAL B and VYMA 2)", November 2001 (unofficial English translation), associated with RAIs 5-4, 5-5, 5-6, and 8-2

Enclosure 22 - Transnuclear Calculation MP1 97HB-0503, Revision 1 associated with RAI 5-20

Page 2 of 4

Enclosure 1 to TN E-29128

Enclosure 24 - DI-DRI-A-1-7-04, Rev. 00 (original, in French) associated with RAI 2-29

Enclosure 25 - DI-DRI-A-1-7-04, Rev. 00 (unofficial English translation) associated with RAI 2-29

Enclosure 26 - Figure 3.2 and 3.3 from BLK 99-074, rev 2, and Pages 45 to 49 from BTF 01221, rev 0, associated with RAI 2-16

Enclosure 32 - Transnuclear Calculation MP197HB-0401, Revision 2 associated with RAI 3-21

Enclosure 34 - Transnuclear Calculation MP197HB-0410, Revision 0 associated with RAI 3-21

Those documents listed which are owned by Transnuclear, Inc. have been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by Transnuclear, Inc. in designating information as a proprietary trade secret, privileged or as confidential commercial or financial information.

Pursuant to the provisions of paragraph (b) (4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced documents, should be withheld.

1) The information sought to be withheld from public disclosure involves certain safety analysis report drawings, analyses, calculations, and computer files related to the design of the modified NUHOMS?MP1 97 transport cask which are owned and have been held in confidence by Transnuclear, Inc., plus certain reports which were obtained under a proprietary agreement with others, and have been held in confidence by Transnuclear, Inc.

2) The information is of a type customarily held in confidence by Transnuclear, Inc. and not customarily disclosed to the public. Transnuclear, Inc. has a rational basis for determining the types of information customarily held in confidence by it.

3) The information is being transmitted to the Commission in confidence under the provisions of 10 CFR 2.390 with the understanding that it is to be received in confidence by the Commission.

4) The information, to the best of my knowledge and belief, is not available in public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.

5) Public disclosure of the information is likely to cause substantial harm to the competitive position of Transnuclear, Inc. and to other owners of the information because:

a) A similar product is manufactured and sold by competitors of Transnuclear, Inc.

b) Development of this information by Transnuclear, Inc. and other owners of the information required expenditure of considerable resources. To the best

Page 3 of 4

Enclosure 1 to TN E-29128

of my knowledge and belief, a competitor would have to undergo similar expense in generating equivalent information.

c) In order to acquire such information, a competitor would also require considerable time and inconvenience related to the development of a design and analysis of a dry spent fuel transportation system.

d) The information required significant effort and expense to obtain the licensing approvals necessary for application of the information. Avoidance of this expense would decrease a competitor's cost in applying the information and marketing the product to which the information is applicable.

e) The information consists of certain safety analysis report drawings, analyses, calculations, and computer files, plus certain reports, related to the design and analysis of dry spent fuel storage and transportation systems, the application of which provide a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to unfairly get a better competitive position with Transnuclear, Inc., take marketing or other actions to improve their product's position or impair the position of Transnuclear, Inc.'s product, while avoiding the expense of developing similar data and analyses in support of their processes, methods or apparatus.

f)

In pricing Transnuclear, Inc.'s products and services, significant research,

development, engineering, analytical, licensing, quality assurance and other

costs and expenses must be included. The ability of Transnuclear, Inc.'s

competitors to utilize such information without similar expenditure of

resources may enable them to sell at prices reflecting significantly lower

costs.

Further the deponent sayeth not.

Vice President, Transnuclear, Inc. Subscribed and sworn to me before this 2 0 th day of April, 2010.

Notary Public My Commission Expires: _/_-_/__/_.__

~' LEWIS A. PICCOLINO

('sEaIa

Notary Public

?-- # Montgomery Co., MD

My Comm. Exps. March 26,2014

Page 4 of 4

RAIs and Responses (non-Droprietarv information)

Enclosure 2 to E-29128

General Information

1-1 Provide the NUHOMS-61 BT heat load zoning configurations used to perform the thermal evaluation of this Dry Shielded Canister (DSC) type inside the NUHOMS-MP197 transportation package.

The Safety Analysis Report (SAR) provides heat load zoning configurations for all the DSC types allowed for transportation in the NUHOMS-MP197 package except the 61BT DSC.

This information is needed to determine compliance with 10 CFR 71 (71.71 and 71.73).

Response to 1-1

The NUHOMS?-61BTDSC has only a uniform heatload zoning configuration(HLZC). Therefore the HLZC for this DSC type was not reportedin the SAR. The uniform heatload configuration for the NUHOMS?-61BTDSC is addedto SAR Section A. 1.4.7 for consistency.

Structural

2-1 Add the statement to all definitions of damaged fuel, "Any assembly that is in a physical condition where it can not meet initial structural assumptions used to determine if criticality, shielding, or thermal requirements are met under either normal or Hypothetical Accident Conditions (HAC) must be considered damaged."

The definition of damaged fuel, as related to transportation, should be unambiguous.

This information is needed to satisfy 10 CFR 71.55 (b)(1), 10 CFR 71.33(b)(3), or 10 CFR 71.55(e)(1).

Response to 2-1

The damagedfuel definition in this TransportSAR applicationis consistent with the Storage SAR. In response to NRC Request for Supplemental Information (RSI) questions associated with this application[1], the definition of damagedfuel was also revised to be consistentwith the criticality,shielding,and thermal analyses. The definitions of damagedfuel for each DSC are listed in:

NUHOMS?-24PTHDSC - Table A. 1.4.3-2 NUHOMS?-32PTHDSC - Table A. 1.4.4-2 NUHOMS?-32PTH1DSC - Table A. 1.4.5-2 NUHOMS?-37PTHDSC - Table A. 1.4.6-2 NUHOMS?-61BTDSC - Table A. 1.4.7-1 NUHOMS?-61BTHDSC - Table A. 1.4.8-2 NUHOMS?-69BTHDSC - Table A. 1.4.9-1

The criticality,shielding, and thermalanalyses assumed that the damagedfuel assembliesdo

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